On June 3, 2026, the White House issued an executive action directing stronger enforcement of U.S. customs laws. This development signals a broader shift in how U.S. imports may be reviewed, documented, and enforced.
For brands importing products into the United States, this is not only a customs paperwork issue. It is a structural compliance issue involving the Importer of Record, also known as the IOR.
The IOR is the party legally responsible for ensuring that imported goods comply with U.S. customs laws, duty obligations, product information requirements, origin rules, and other applicable regulations. As U.S. customs enforcement becomes more rigorous, brands will need to review not only what they are importing, but also who is responsible for the import and whether that structure can be supported with accurate documentation.
Why the IOR Structure Matters
The U.S. government is placing greater emphasis on whether the Importer of Record can be properly identified and held accountable. This may include closer review of the importer’s business information, bonding, ownership or beneficial ownership details, and ability to respond to CBP inquiries.
For overseas brands, this is especially important. In the past, some brands have used a Foreign Importer of Record, or FIOR, structure without a strong U.S.-based import infrastructure. Under the new enforcement direction, FIOR models may face greater scrutiny, particularly for informal entries, low-value shipments, small-parcel flows, and import structures that lack clear documentation.
Formal entry may still be available in certain cases, but customs bonds, qualified customs brokers, CBP review, and compliance assurance may become more important. For this reason, CGETC does not view FIOR as a reliable default structure for long-term U.S. market operations.
Brands should review whether their current import model includes a clear U.S. IOR structure, a qualified U.S.-based import infrastructure partner, or a stronger formal entry process managed through appropriate customs and compliance channels.
Import Documentation Will Become More Important
As customs enforcement strengthens, incomplete or unclear documentation may increase the risk of delays, holds, penalties, or other disruptions. Before shipping products to the United States, brands should be prepared to provide accurate and consistent records related to the product, manufacturer, country of origin, value, supply chain, and applicable compliance requirements.
Key records may include:
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Basic customs documents
Commercial Invoice, Packing List, Bill of Lading, Air Waybill, and related shipping records. -
Product information
Product name, model, SKU, specifications, composition, ingredients, intended use, size, grade, and other product-level details. -
Manufacturer information
Manufacturer name, address, manufacturing country, and actual production site. -
Country of origin support
Country of Origin basis, origin marking information, and supporting records that explain where and how the product was made. -
Value support
Actual transaction value, payment terms, Incoterms, discounts, credits, and related-party information when applicable. -
Export records
Korean or other foreign export declaration records and supporting documents. -
Product-specific compliance records
FDA, MoCRA, FSVP, FWS, Prop 65, or other applicable regulatory documentation depending on the product category.
Regulated Product Categories May Require Additional Review
Certain product categories may require more detailed pre-import review due to their regulatory sensitivity. These may include cosmetics, food products, dietary or functional products, products containing animal-derived ingredients, sunscreens, children’s products, electronics, and other regulated goods.
For example, cosmetics may require MoCRA-related readiness, while food products may involve FDA and FSVP considerations. Sunscreens may require additional review because they are generally regulated as OTC drugs in the United States. Products with animal-derived ingredients or special material claims may also require additional documentation depending on the product type and import conditions.
CGETC’s Readiness Plan
CGETC is preparing to strengthen its pre-import review process to help reduce risk for clients and support more stable U.S. operations.
By July 2026 | Client Risk Review
CGETC will review client import structures, IOR arrangements, product categories, and documentation readiness.
By September 2026 | Stronger Pre-Import Documentation Standards
CGETC will organize required document standards and request missing information from clients. Shipments with unclear origin, value, manufacturer, or product information may be delayed or placed on hold.
By November 2026 | IOR Approval Process
When CGETC acts as an IOR or import infrastructure partner, clients may be required to complete a pre-approval process. This process is intended to help protect both the client and CGETC.
After July 2027 | Greater Importance of U.S. Inventory and Domestic Fulfillment
As the U.S. import environment continues to change, U.S.-based inventory, domestic fulfillment, and a clear import structure may become increasingly important for stable long-term operations.
Recommended Actions for Brands
Brands importing into the United States should begin reviewing their current import structure and documentation readiness. Key action items include:
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Confirm the current IOR structure and whether FIOR is being used.
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Organize manufacturer, origin, specification, and ingredient records by product.
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Confirm that Commercial Invoice values match the actual transaction structure.
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Keep export declaration records and supporting documents.
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Update product-specific compliance records, including FDA, MoCRA, FSVP, FWS, Prop 65, or other applicable requirements.
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Request pre-import review before launching new products or shipping new product categories.
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Review long-term U.S. import, inventory, and fulfillment operations.
CGETC’s Role
CGETC is more than a warehouse provider. CGETC serves as a U.S.-based infrastructure partner connecting import support, compliance coordination, warehousing, fulfillment, and distribution for Korean and global brands entering the U.S. market.
The strengthened customs enforcement environment may create additional preparation requirements for brands. However, it also gives prepared companies an opportunity to build a more stable and reliable U.S. operating structure.
Brands with a clear IOR structure, accurate product information, verified manufacturer and origin records, and strong compliance documentation will be better positioned to reduce the risk of customs delays, penalties, shipment holds, and marketplace disruptions.
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The U.S. import environment is becoming more rigorous. IOR accountability, FIOR structure, customs documentation, product-level records, and compliance readiness should be reviewed before goods are shipped.
CGETC will continue to support clients in preparing for these changes and building a more reliable U.S. import and fulfillment structure.
Note: This article is provided for general business planning purposes only and does not constitute legal advice. Final requirements and implementation details may change through DHS, CBP, or other government agency rulemaking and guidance.